The U.S. Court of Appeals for the Sixth Circuit affirmed a district court's summary judgment dismissing racial discrimination claims filed by a former Detroit Water and Sewerage Department employee against the city and her supervisor.
In *LaDonna Blewett v. Nikole Howard-Whisett* (6th Cir. 2026), the appeals court upheld the dismissal of claims alleging violations of the Equal Protection Clause and Michigan state law. Circuit Judge Jane B. Stranch wrote the opinion for a three-judge panel that included Chief Judge Jeffrey S. Sutton and Circuit Judge Joan L. Larsen.
Blewett, who is African-American, worked as a professional administrative analyst in the treasury department of the Detroit Water and Sewerage Department beginning in 2016. In this role, which was also referred to as a staff accountant position, her primary responsibilities included processing incoming and outgoing wire transfers, reconciling issues with those transfers, and maintaining a daily cashbook log.
According to court documents, Blewett was required to submit her cashbook to her supervisor, Nikole Howard-Whisett, daily between 11 a.m. and 12 p.m. Howard-Whisett would then forward the cashbook to another department for additional review. The appeals court noted that this daily submission requirement was a key aspect of Blewett's job duties.
After Blewett was terminated from her position, she filed suit against both the City of Detroit and Howard-Whisett individually. Her complaint alleged that the defendants engaged in racial discrimination that violated her rights under the Equal Protection Clause of the Fourteenth Amendment. She also brought claims under Michigan state law.
The case proceeded through the U.S. District Court for the Eastern District of Michigan, where the defendants sought summary judgment on all claims. The district court granted summary judgment in favor of both Howard-Whisett and the City of Detroit, effectively dismissing Blewett's lawsuit in its entirety.
Blewett appealed the district court's ruling to the Sixth Circuit, which has jurisdiction over federal appeals from Michigan, Ohio, Kentucky, and Tennessee. The case was heard by a three-judge panel, which is standard practice for most federal appeals.
In its decision filed Jan. 21, 2026, the Sixth Circuit affirmed the lower court's summary judgment ruling. The appeals court found that the district court properly dismissed all of Blewett's claims against both defendants. The opinion was marked as "not recommended for publication," which means it will not serve as binding precedent for future cases but can still be cited as persuasive authority.
Summary judgment is a procedural device that allows courts to resolve cases without a trial when there are no genuine disputes about material facts and the moving party is entitled to judgment as a matter of law. For the defendants to prevail on summary judgment in an employment discrimination case, they typically must show either that the plaintiff cannot establish the basic elements of her discrimination claim or that they had legitimate, non-discriminatory reasons for the employment action.
The Equal Protection Clause of the Fourteenth Amendment prohibits state and local governments from denying individuals equal protection under the law. In the employment context, this means government employers cannot make employment decisions based on an employee's race, gender, or other protected characteristics. To succeed on an Equal Protection claim, a plaintiff must typically show that she was treated differently from similarly situated employees of a different race and that race was a motivating factor in the employer's decision.
Michigan state law also provides protections against employment discrimination through the Elliott-Larsen Civil Rights Act, which prohibits discrimination in employment based on religion, race, color, national origin, age, sex, height, weight, familial status, or marital status.
The Sixth Circuit's affirmance means that Blewett's legal options are now limited. She could potentially seek review by the Supreme Court through a petition for writ of certiorari, though the high court accepts only a small percentage of such petitions. Without Supreme Court review, the Sixth Circuit's decision stands as the final word in this case.
Employment discrimination cases involving municipal water departments and utilities are relatively common, as these entities are considered state actors subject to constitutional constraints. The outcome in *Blewett* adds to the body of case law addressing how federal courts evaluate discrimination claims against municipal employers.
The case also illustrates the challenges plaintiffs face in employment discrimination litigation, particularly at the summary judgment stage where courts examine whether there is sufficient evidence to allow a case to proceed to trial. The specific facts underlying the district court's decision to grant summary judgment were not detailed in the appeals court's brief opinion, which focused primarily on affirming the lower court's legal conclusions.